PEOPLECLICK AUTHORIA PRIVACY POLICY

(Effective January 2011)

The Peopleclick Authoria companies (“Peopleclick Authoria”) provide this Privacy Policy to explain how we collect, use and disclose certain personal information online. By using this web site or our hosted web-based application services or related support services, you are accepting the practices described in this Privacy Policy.

Peopleclick Authoria is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent organization whose mission is to build users’ trust and confidence in the Internet by promoting the use of fair information practices. This Privacy Policy covers the Web site www.peopleclickauthoria.com. Because Peopleclick Authoria wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

Information We Collect

Peopleclick Authoria may collect information on its own behalf on its web sites as described in this Policy. In addition, Peopleclick Authoria provides web-based application services and related support services to recruit and manage our customers’ permanent and contract workforce and to perform compensation and performance management and succession planning, as well as integrated EEO software and expertise in affirmative action and diversity planning.

The types of personal information we may collect about you through our sites include contact and identifying information (name, address, email address, phone and fax numbers, institution, title or job position), information about your interest in Peopleclick Authoria products or services, information about your interest in newsletters, seminars, or other services that we provide (solely or jointly with others), information about any other transaction(s) between you or your organization and Peopleclick Authoria and any other personal information that you may provide to us in an online form or through an email. Where we collect personal information through online forms, we will notify you of which fields are mandatory for the particular service or functionality you are requesting and which fields are optional. If you choose to provide information that is optional, we may use and disclose such information as described in this Policy. A visitor to www.peopleclickauthoria.com who is not seeking employment and not expressing an interest in purchasing products or services is not required to reveal any individually identifiable information such as name, address or telephone number.

Our customers may use our hosted application services to process data about their candidates, employees, contractors and agents. Personal data that Peopleclick Authoria may maintain on behalf of our customers includes, but is not limited to, names, contact information, CV or resume, data of birth, national insurance numbers, social security numbers, compensation information, and race and ethnic origin. Peopleclick Authoria does not own or control any of the information it processes on behalf of its customers. Such information is owned and controlled by the customer, and Peopleclick Authoria receives such information merely as a processor on the customer’s behalf. We use such data only as authorized in our subscription agreements with such customers and in accordance with applicable law. Customers are responsible for maintaining the security of their own user logins.

Testimonials

Peopleclick Authoria posts customer testimonials on its web site which may contain personally identifiable information such as the customer’s name. Peopleclick Authoria obtains the customer’s consent prior to posting the testimonial to post their name along with their testimonial. If you wish to remove your personal information that is being displayed on our public Web pages please send your request to Security@peopleclickauthoria.com.

Newsletters

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe by providing a functional unsubscribe mechanism in each email communication we send to users.

Financial Information

We may offer products or services and event or class registration for you to purchase online. To complete these online financial transactions, our sites may request personal information including contact information (such as name, title, email address or shipping address) and credit card billing information. Disclosure of this information is completely voluntary and you have a choice whether or not to disclose this information.

Surveys & Contests

From time-to-time our sites may request personal information from you in connection with surveys or contests. Participation in these surveys or contests is completely voluntary and you have a choice whether or not to disclose this information. Personal information requested may include contact information (such as name and shipping address), and demographic information (such as zip code). Contact information will be used to notify the winners and award prizes, and may also be used to provide you with additional information about our products or services, or those of our selected business partners.

Cookies

Peopleclick Authoria may use non-persistent cookies in conjunction with its hosted applications services. A cookie is a small piece of data that is sent to your browser from a web server and stored on your computer's hard drive. A cookie does not read data off your hard disk or read cookie files created by other sites. We use cookies to maintain the context of an indvidual’s interaction with the our Web site or with the hosted service application. You can choose whether or not to accept cookies by changing the settings of your browser. If you choose not to accept cookies, your experience at our Web site and at the hosted service application Web site may be diminished and some features may not work as intended.

Log Files and Aggregate Information

Peopleclick Authoria may record information that is not individually identifiable about how people access our Web sites. This information includes IP addresses (or the DNS name associated with it), the web site from which you are visiting Peopleclick Authoria and the Web software you are using. This information is used in the aggregate, without disclosure of any individually identifiable information, to administer our system and make improvements to our site and to report to our customers and prospects on our sites’ performance. We reserve the right to share aggregate and anonymous information with potential partners and other third parties without restriction.

Links

Peopleclick Authoria’s Web site may contain links to other Web sites. Peopleclick Authoria is not responsible for the privacy practices or the content of such Web sites, and this Privacy Policy does not apply to such sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information.

Disclosure

We may disclose personal information as necessary or appropriate in connection with any of the purposes for which we use personal information, including to subcontractors or service providers that help host or support the sites or otherwise provide technical assistance, fulfillment companies that help us to provide requested products or services and business partners that help conduct seminars or otherwise provide requested products, services or information. We may use third party service providers to provide credit card processing on our site. We will share your credit card information as necessary for the third party to provide such processing services. We reserve right to disclose personal information in connection with the sale or transfer of all or part of the business. In situations where we transfer personal information to these types of third parties, we require that such third parties must not use or disclose the information for any purposes other than those specified in this Privacy Policy, and that such third parties must maintain commercially reasonable security measures to protect the personal information. In situations involving the sale or transfer of all or part of the business, we will seek to notify users of the ownership change by way of a prominent notice posted on our Web site. We also reserve the right to disclose your personally identifiable information as required by law and or in the good faith belief that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process. Peopleclick Authoria does not share, sell, rent, or trade personal information with third parties for their promotional purposes.

Security

To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use of personal information, Peopleclick Authoria has adopted appropriate physical, electronic and managerial procedures to safeguard and secure the personal information we process. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Data maintained by Peopleclick Authoria is protected by computer security mechanisms including firewalls, encryption, monitoring software, data and network segmentation, and passwords. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. If, during their employment, Peopleclick Authoria employees acquire confidential or proprietary information belonging to Peopleclick Authoria or its customers, such information is required to be handled in confidence and may not be disclosed to unauthorized third parties. Peopleclick Authoria employees are also responsible for the internal security of such information. Peopleclick Authoria provides information and training to all employees who have access to data maintained on behalf of Peopleclick Authoria customers. Employees who violate Peopleclick Authoria security and safe maintenance of data policies are subject to appropriate discipline including, but not limited to, termination. If you have any questions about our security practices, you can email us at Security@peopleclickauthoria.com.

Safe Harbor

Personal information may be transferred abroad (including outside the EU and Switzerland for our users in the EU and Switzerland) in connection with Peopleclick Authoria’s provision of hosted application services and related support services to our customers. Peopleclick Authoria strives to collect and use personal information in a manner consistent with the laws of the countries in which we do business and is self-certified to United States-EU and Swiss Safe Harbor framework developed by the U.S. Department of Commerce in coordination with European Commission and the Swiss Federal Data Protection and Information Commissioner (FDPIC). For more information, see http://www.export.gov/safeharbor. Peopleclick Authoria is committed to cooperating with the European Data Protection Authorities and the FDPIC or their authorized representatives in any dispute raised with respect to an EU or Swiss data subject’s personal information.

To Unsubscribe or Modify Information

If you receive marketing or similar e-mail messages from us and you wish to opt out of receiving such messages, you may follow the opt-out procedure specified in the e-mail message or you may contact Security@peopleclickauthoria.com. Peopleclick Authoria intends to protect the quality and integrity of your personal information. If you wish to review or modify information submitted to us directly, you should contact Security@peopleclickauthoria.com. If you are an applicant, employee or are otherwise affiliated with a Peopleclick Authoria customer and wish to review or modify information provided to Peopleclick Authoria via a Peopleclick Authoria hosted service application, you should first contact the Peopleclick Authoria customer to whom you submitted such information, or who has otherwise provided the information to Peopleclick Authoria for processiing. If such company is unable or unwilling to assist you, you should contact Peopleclick Authoria at Security@peopleclickauthoria.com or to Peopleclick Authoria Security at the contact information set out below. Within 30 days of your request, Peopleclick Authoria will grant individuals reasonable access to personal information that it holds about them and take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

Changes to this Web Site Privacy Policy

Peopleclick Authoria reserves the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to this Policy, we will re-post the revised policy here or at another location that is accessible from our home page so that you are aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to use personal information in a manner that is substantially different from that stated at the time we collected it, we will seek to notify users by way of an email, and provide users with a choice as to whether or not we use their information in this different manner.

Oversight/Enforcement

Peopleclick Authoria’s Chief Security Officer is responsible for Peopleclick Authoria’s compliance with and enforcement of this Privacy Policy; the Chief Security Officer may be reached at Security@peopleclickauthoria.com. The United States Federal Trade Commission is the statutory body that has jurisdiction to hear any claims against the organization regarding possible unfair or deceptive practices and violations of laws or regulations governing privacy. In addition, Peopleclick Authoria is committed to cooperating with the appropriate EU and Swiss Data Protection Authorities or their authorized representatives as an independent third party recourse mechanism for any individual who believes their personal data protection has been violated.

Questions/Concerns

If you have questions or concerns regarding this Privacy Policy, you should first contact Security@peopleclickauthoria.com by email. If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you should then contact TRUSTe through its Watchdog Dispute Resolution Process at: http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with us to resolve your concerns.

Contact Information

If you have any questions or suggestions regarding our privacy practices or this Policy, please contact us at: